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This is an error – and has been such since 2013, when s. 120.2(3)(b) was amended to exclude TOSI from the downward adjustments to the adjusted Part I ordinary tax liability for the year that is used in computing the additional tax. ... The CRA does not have a general administrative policy on the implications of a correction to a CRA form that may result in a reassessment for prior taxation years. … With respect to the amendment to Form T691, the CRA will correct the application of subsections 120.2(1) and 120.2(3), but will not issue reassessments for taxation years prior to 2021 changing the amount of tax payable that relates to that correction. ...

7 October 2022 APFF Roundtable Q. 11, 2022-0942751C6 F- Changement de fin d'exercice et opposition-- summary under Subsection 249.1(7) Summary Under Tax Topics- Income Tax Act- Section 249.1- Subsection 249.1(7) a corporation cannot change its year end by objecting to the 1st year’s initial assessment 2020-0874951I7 indicated that if a request for a retroactive change to a taxation year is made after the corporate tax returns are filed but before the first Notice of Assessment for that year is issued, it will generally be granted – but not if such request is made after such issuance. ... [Here] … there is nothing to suggest that the assessment of February 20, 2022 would be invalid or unfounded so as to justify its cancellation by the Minister under subsection 165(3) More specifically, the mere fact that the corporation wishes to change the timing of its fiscal period end after tax has been assessed for the year corresponding to the fiscal period, even if it is the corporation's first fiscal period, does not, in and of itself, invalidate or render unfounded the assessment of February 20, 2022. ...

(a) CRA noted that it “recognize[d] that the ‘all or substantially all’ test could be met even if the 90% threshold is not satisfied, depending on the circumstances and context” and further noted that if one of “the asset tests described in the definition of QSBCS in subsection 110.6(1) (more than 50% or all or substantially all) must be satisfied at all times during the relevant period …. is not met during the relevant period, even for a short period, a share of the capital stock of a corporation will not qualify as a QSBCS.” (b) CRA stated: Holdco has an interest in the dividend declared by Opco and … the interest in such a dividend is an "asset" for the purposes of the definition of QSBCS, regardless of whether it is recorded on the corporation's balance sheet. ...

CRA then stated: The disposition of the shares … of Opco by Husband, Wife and Third Party to Holdco would not result in a disposition described in subparagraph 55(3)(a)(i), (ii) or (v) as, immediately before the disposition, Holdco would be related to Opco and Realtyco, the dividend recipients. However, the investment of Third Party in Holdco … would result in an increase in interest described in subparagraph 55(3)(a)(ii) as Third Party would be…unrelated to Opco and Realtyco, the dividend recipients. Finally, the investment of Holdco in Opco…would not constitute an increase in interest described in subparagraph 55(3)(a)(ii) and (v) as … Holdco would be related to Opco and Realtyco immediately before the transfer of the shares. ...

CRA then stated: The disposition of the shares … of Opco by Husband, Wife and Third Party to Holdco would not result in a disposition described in subparagraph 55(3)(a)(i), (ii) or (v) as, immediately before the disposition, Holdco would be related to Opco and Realtyco, the dividend recipients. However, the investment of Third Party in Holdco … would result in an increase in interest described in subparagraph 55(3)(a)(ii) as Third Party would be…unrelated to Opco and Realtyco, the dividend recipients. Finally, the investment of Holdco in Opco…would not constitute an increase in interest described in subparagraph 55(3)(a)(ii) and (v) as … Holdco would be related to Opco and Realtyco immediately before the transfer of the shares. ...

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CRA stated: [A]n obligation such as the one described in the above example is not an obligation described in paragraph 7000(1)(b) …. ...

15 June 2022 STEP Roundtable Q. 14, 2022-0930221C6- Info on new T3 EFILE process-- summary under Paragraph 150(1)(c) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1)- Paragraph 150(1)(c) now efiling T3 returns CRA noted that its: EFILE web service is now accepting transmissions of T3 returns (currently limited to only 2021 and subsequent tax years T3RET, T3S, T3M, T3RCA & T3ATH-IND return types) and T1135 Foreign Income Verification Statements. ...

8 October 2010 Roundtable, 2010-0373291C6 F- Tuck-Under Transactions- Safe Income Extractions-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income can be extracted using tuck-under In the course of indicating that, in some instances, it would consider applying ss. 84(2) and 245(2) to tuck-under transactions, CRA stated: T]he CRA maintains its long-standing position that subsections 84(2) and 245(2) should not apply to a "tuck under" transaction to extract the safe income on hand relating to the interest of a corporate taxpayer in a target corporation …. ...

RDTOH and Dividend Refunds-- summary under Subsection 129(1.2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1.2) " In response to a request for an update on its position on s. 129(1.2), CRA noted that it had issued favourable s. 129(1.2) rulings on post-mortem estate planning transactions (2004-008855, 2010-0377601R3 and 2012-0456221R3) and further stated that where the purpose test in s. 129(1.2) was met, s. 129(1.2) could technically apply to deny a dividend refund to a payer corporation even if tax was paid by the shareholder on the dividend received from the payer corporation. ...